BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN INDEPENDENT HEARINGS … · 2015-05-01 · BEFORE...
Transcript of BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN INDEPENDENT HEARINGS … · 2015-05-01 · BEFORE...
GJC-291666-3-89-V1
BEFORE THE CHRISTCHURCH REPLACEMENT DISTRICT PLAN INDEPENDENT HEARINGS PANEL
IN THE MATTER of the Resource Management Act 1991 ('the Act') and the Canterbury Earthquake (Christchurch Replacement District Plan) Order 2014
AND
IN THE MATTER
the Christchurch Replacement District Plan: Proposal 15 (Commercial).
REBUTTAL EVIDENCE OF JAMES DICKSON LUNDAY ON BEHALF OF DANNE
MORA HOLDINGS LIMITED
(Submitter No. FS-1430)
Dated: 01 May 2015
1134 Danne MoraRebuttal: James Lunday with annexures
page 1 of 20
GJC-291666-3-89-V1 Page 2/13 Page 2/13
INTRODUCTION
1 My full name is James Dickson Lunday.
2 My qualifications and experience are set out in my evidence in chief, dated 24
April 2015.
3 I have read the Environment Court's Code of Conduct and agree to comply
with it. I confirm that the issues addressed in this statement of evidence are
within my area of expertise.
4 The data, information, facts and assumptions I have considered in forming my
opinions are set out in the part of the evidence in which I express my opinions.
I have not omitted to consider material facts known to me that might alter or
detract from the opinions I have expressed.
SCOPE OF REBUTTAL
5 This rebuttal evidence responds to the evidence-in-chief of Jacobus (Kobus)
Marthinus Mentz, dated 24 April 2015 in particular his Figures 1-14.
Figures 1 to 2
6 In my opinion these figures fail to properly explain the wider context of the
proposed location of the Key Activity Centre (KAC) within the North Halswell
ODP. In particular:
• The figures ignore the council owned Douglas Clifford stormwater
basin immediately to the south of the TDS proposed ODP. This facility
is approximately 4.7 hectares in total and therefore represents a "void"
as Mr Mentz appears to use that term;
• The aerial used in figures 1 and 2 is outdated and therefore fails to
show the existing Aidanfield housing development on the north west
side of Halswell Road, development which is shown in his figures 3
and 4;
1134 Danne MoraRebuttal: James Lunday with annexures
page 2 of 20
GJC-291666-3-89-V1 Page 3/13 Page 3/13
• These figures fail to acknowledge the already zoned Meadowlands
Exemplar housing, which is partially shown in his figure 3 & 4;
• The figures do not identify Augustine Drive that connects to Nga Puna
Wai reserve, or the planned extension of Augustine Drive from
Halswell Road to Sparks Road; and
• Fail to recognise the proposed Nga Puna Wai regional sports hub (as
approved by the Council on 12 March 2015) which is to be located in
the area indicated by Mr Mentz as a void. Not only will this become a
heavily used centre for the south west but facilitate a new local traffic
circulation from McMahons to Augustine Drive.
7 The intention is to connect McMahon Road in Aidanfield with the new
Augustine Drive, via the sports hub, where it is intended to have a controlled
intersection at Halswell and Augustine.
8 The distance between the boundary of the proposed KAC and Nga Puna Wai
along Augustine Drive is approximately 250 metres (less than the length of the
Main Street) and is certainly a walkable distance. The proposed KAC will
therefore be highly accessible to the users of Nga Puna Wai, and vice versa.
9 Therefore, Nga Puna Wai and the proposed KAC operate as a major business
and community hub for the south west. The importance of the Augustine
connection should not be understated. Nga Puna Wai is a city wide facility – a
home for multiple sports, attracting participants and supporters.
10 I have produced a more complete contextual analysis and in my opinion, when
the missing context is considered, to use Mr Mentz’s phrase the CCC KAC is
in fact the "centre of gravity”.
1134 Danne MoraRebuttal: James Lunday with annexures
page 3 of 20
GJC-291666-3-89-V1 Page 4/13 Page 4/13
Figure 1. KAC context
Figures 3 and 4
11 The shape identified by Mr Mentz in his figure 4 is, in my opinion, artificial and
is not representative of the Outline Development Plan for the KAC. The
Centre is not wedged in the corner, rather it sits within a much larger wider
environment (see context plan above).
12 The arrows used by Mr Mentz in figure 4 are significantly shorter than the
equivalent arrows used by him in figure 3. If one were to use equivalent
arrows then they would extend into an existing residential catchment to the
north east. The arrows infer the KAC is only servicing Greenfield areas as opposed
to existing development areas and the wider south west catchment.
Figures 5 to 8
13 Figure 5 is redundant as it is outdated. It has been superseded in the
Caucusing Agreement.
14 Figure 6 does not represent the 26.7 ha sought in TDS’s ODP and figure 20
which illustrates 31.9ha. Our CAD calculation of his master plan shows
1134 Danne MoraRebuttal: James Lunday with annexures
page 4 of 20
GJC-291666-3-89-V1 Page 5/13 Page 5/13
78,000m2 of footplate. That would amount to an inefficient 29% coverage. If
this same footplate was applied to the smaller 17.3 hectare ODP, the
coverage increases to a still acceptable 45%. I do not consider all activities at
ground level desirable for the Centre.
15 Mr Mentz introduces in figure 6 artificial “large” and “small” KAC options.
These do not correlate with the Council ODP shape or with TDS's larger ODP
shown in figure 20. I consider these are not helpful in determining the KAC
catchment. We have redrafted the KAC's shown in figure 20 to provide a
correct and transparent comparison between the Council’s 17.3 hectare and
the 31.9 hectare ODP identified in Mr Mentz’s figure 20.
16 The corrected catchment diagrams show the CCC KAC delivers 28ha of
potential medium density residential land, whilst the TDS ODP delivers
19.9ha.
Figure 2. Revised Catchment diagrams (*refer to appendix for full size)
1134 Danne MoraRebuttal: James Lunday with annexures
page 5 of 20
GJC-291666-3-89-V1 Page 6/13 Page 6/13
Figure 3. Revised Catchment diagrams with CCC ODP (*refer to appendix for full size)
17 I have emphasised the areas rather than the potential number of households
as there is some uncertainty around what final density may occur. For
example, there is flexibility around the residential intensification target of 15
households per hectare i.e landowners may choose to develop to a higher
density Equally, 30 households per hectare medium density housing "in or
near" KAC's is not required in the Proposed Replacement District Plan.
Figures 9 to 11
18 The location of the Transport Interchange is an indicative feature only within
the ODP. The final location of the Interchange will be determined after
discussions with, amongst others, Environment Canterbury, the Christchurch
City Council and NZTA.
1134 Danne MoraRebuttal: James Lunday with annexures
page 6 of 20
GJC-291666-3-89-V1 Page 7/13 Page 7/13
19 The location indicated in figure 9, in my opinion, would be too remote to fit into
the wider transport (public) network, particularly with the creation of Nga Puna
Wai sports complex which will be serviced by public transport.
20 Given the strong pedestrian flows likely between the KAC and Nga Puna Wai,
supported by a signalised intersection at Augustine Drive providing a safe and
legible crossing point, it is my opinion the Interchange is more likely to be in a
northern location.
Figure 12
21 The Common Ground design used by Mr Mentz for his analysis is an early
indicative design only and is out of date. I have supplied our latest indicative
design in my evidence in chief.
22 In Mr Mentz’s evidence he questions the practicality of irregular block and
building shapes. In my opinion, irregular shapes and non-orthogonal grids
create a better opportunity to provide for all the elements of good place-
making. As well illustrated in the Rouse Hill development mentioned by Mr.
Mentz, irregular shapes facilitate more built form variety and interest that in
turn helps place making, and supports increased legibility and way finding.
Figure 13
23 Mr Mentz has used an out of date conceptual plan in Figure 13 instead of the
Council ODP. The movement system in the Council ODP is based on an
inner and outer circulation route, intersected by a lower car
movement/pedestrian orientated Main Street. Bus traffic, car access and
parking manoeuvres around the core pedestrian orientated mixed use town
centre core. The movement network facilitates development of all land owners
sites and minimises the amount of land taken up by roads.
24 The TDS larger KAC framework also appears not to reflect their ODP (figure
20). There is a very strong reliance of their Main Street attracting traffic, based
on a theory that retail will only work in a heavily trafficked area. I dispute this,
I also dispute that their movement system would encourage cars to use the
Main Street. Access to the Main Street does not give access to the car parks.
1134 Danne MoraRebuttal: James Lunday with annexures
page 7 of 20
GJC-291666-3-89-V1 Page 8/13 Page 8/13
25 The main entry to the Main Street from either the proposed Halswell southern
entry(s) or Augustine Drive is complex and not legible. The road layout has
no understandable hierarchy, no real centre or core, and a very poor internal
circulation network. It would involve building a large road network to unlock all
the land owners and does not appear to recognise the complexities of staging
development and land ownership. It is land hungry.
26 Mr Mentz's roading network is over-complex and will not deliver a mixed use
walkable environment, has poor visibility and a Main Street that will attract
neither foot traffic nor cars.
Figure 14 & 15
27 In figure 14 Mr Mentz proposes a possible master plan for the TDS ODP.
Again this doesn't appear to represent the TDS ODP presented in figure 20.
Figures 14 & 15 are presumably intended to demonstrate his views on town
making opportunities and community, civic and public realm objectives. He
does not appear to take into account Councils current intentions to retain the
library, swimming pool and other sporting facilities outside the current KAC.
28 He refers to Rouse Hill as an example of good design. He says that his TDS
design is based on similar principles. Having just recently visited Rouse Hill for
the purposes of providing this evidence I cannot agree with his conclusion.
Rouse Hill does demonstrate good design but has a completely different form
and mix of uses not reflected in the TDS proposal.
29 There is a depth of research and literature about successful place making
(Sitte, Christopher Alexander, Gordon Cullen, Rob and Leon Krier et al).
Urban design theory and best practise divide areas into positive and negative
spaces, agree that containment of space, permeable connections, small grain
block patterns, a relationship of height to width of space and a compact
walkable environment that contains 24hr activities (mixed use), the major
elements of place making. These elements are not found in the TDS master
plan.
30 I have used Nollie diagrams to assess space qualities and permeability of
Nollie of Rouse Hill Centre in comparison to the TDS proposal. You see a
contrast in the pattern of built to unbuilt space between the two. Mentz’s
1134 Danne MoraRebuttal: James Lunday with annexures
page 8 of 20
GJC-291666-3-89-V1 Page 9/13 Page 9/13
master plan has large grain buildings, low level of permeability, has negative
spatial forms and is so large and poorly integrated that it is not conducive to a
24hrs mixed use walkable environment.
31 Given Mr Mentz’s criticism I include a Nollie of an indicative master plan
design for a KAC within the Council ODP , a design which is more reflective of
Rouse Hill.
Figure 4. Nollie comparisons
1134 Danne MoraRebuttal: James Lunday with annexures
page 9 of 20
GJC-291666-3-89-V1 Page 10/13 Page 10/13
32 The TDS design appears to be based on a ‘Big Box’ development. In my
opinion the layout will create a poorly functioning Main Street environment.
Stripping their design back to its basic elements and core drivers is
represented in a simple diagram.
Figure 5. TDS design framework
33 The layout has 4 large ‘boxes’ that front to large car parks providing ‘first
encounter’ access, with limited connection to the Main Street. The Main
Street has been formed by leaving the rear of the big boxes with smaller retail.
This may or may not happen. The major retailers of the size indicated –
supermarkets, the Warehouse, Harvey Norman, Bunnings, Placemakers to
name some – are all destinations. They have little regard for specialty retail. I
do not believe that approach will deliver a Main Street environment that will
work.
34 The Master Plan in figure 14 does not in my opinion satisfy the policies and
objectives of the KAC. It fails to deliver quality urban design outcomes:
1134 Danne MoraRebuttal: James Lunday with annexures
page 10 of 20
GJC-291666-3-89-V1 Page 11/13 Page 11/13
• Policy 15.8.2.4 - the large centre does not promote an efficient use of
land or achieve a compact urban form. This is a large sprawling, car-
focussed destination retail complex, where the focus on big box,
delivering over 78,000m2 illustrated at grade and an over-provision of
parking, as a result of each big box requiring its own standalone
parking space.
• Has a low level of legibility to access the Centre by car or foot.
o Has a small left in, but not left out, access to the centre from
Halswell Road.
o No access from Aidanfield Drive, and;
o Proposes a new entry that is not part of the ODP in addition to
Dunbars Road
• The first entry off Augustine Drive takes you to a cul-de- sec, The
second entry leaves you with two choices:
o Access to car parks (with no visual access to car parks) or;
o Drive down Main Street with no access to car parking
• Big box and other anchor stores access from major at-grade car parks.
There is limited reason to access the main street with a low level of
permeability.
• The civic square is compromised by the Main Street bisecting it. It is
over-sized, is not fronted by active uses and is at the fringe of the
Centre. There is no requirement for a Market Square in the ODP. It
creates two competing Squares.
• The road layout and parking creates an inefficient use of land
• Residential is relegated to the main entry corner. The core retail has
no residential in it. The safety of the area is compromised after retail
hours.
• The scale, distances and impediments of car parks make this a hostile
walking environment.
1134 Danne MoraRebuttal: James Lunday with annexures
page 11 of 20
GJC-291666-3-89-V1 Page 12/13 Page 12/13
• The Centre is not legible for pedestrians, traffic or passing traffic – the
Main Street has no visibility from surrounding roads
35 The LURP and RPS, and Chapter 15, envisage a mixed use area – which in
urban design terms means having apartments on top of, and within the
Centre. The Mentz design does not, and would not, achieve this. The nature
and form of the movement network, parking and design of Main Street
relegates this to a destination Centre with no urban place making as exhibited
in traditional Centres or expected in the District Plan’s policies for North
Halswell KAC.
CONCLUSION
36 Having looked at the evidence prepared by Mr Mentz and analysed his
diagrams, and offered accurate and corrected analysis of these, I see no need
to change the location, size or shape of the KAC to accommodate a Centre of
the size indicated by TDS. In my substantive evidence I have demonstrated
how the Centre can be achieved.
37 In this rebuttal, I have included an indicative master plan to further show one
way of achieving this. I believe the Council KAC ODP is sufficiently adaptable
and flexible to absorb a number of variations of this design. It can achieve this
in a compact form with the majority of parking at grade – or like most other
centres, there can be a blend of at grade and covered parking. It delivers a
pedestrian focussed Centre without putting the same design demands on
neighbouring properties
38 The draft master plan is not a retail mall as TDS witnesses infer will be the
only outcome for a KAC within the Council ODP. A mall provides solely for
retail spaces and other commercial services, relegating residential to the
fringe of the mall and does not incorporate residential above. The attached
master plan shows how to provide regular shaped footplates for large format
retail which is accessed from the Main Street and in close proximity car parks.
In accordance with the LURP and the RPS, the design facilities a residential
1134 Danne MoraRebuttal: James Lunday with annexures
page 12 of 20
GJC-291666-3-89-V1 Page 13/13 Page 13/13
environment within the centre. This is achieved through good urban design
within 17 hectares.
39 TDS have proposed a larger KAC than anticipated by CCC. Mr Mentz and Mr
Cullen try to justify a larger KAC based on Aidanfield Road being the main
entry long term and hence being the centre of activity, and a design that
anticipates a dominance of ‘Big Box’ retailers.
40 Their contextual analysis misrepresents the Council KAC, located as part of
an existing and developing environment. The size of TDS land holding has
driven the Mentz design resulting in it not being compact or walkable in
nature.
James Lunday
01 May 2015
1134 Danne MoraRebuttal: James Lunday with annexures
page 13 of 20
1134 Danne MoraRebuttal: James Lunday with annexures
page 14 of 20
client:
© CopyrightThe concepts & information contained on this plan are copyright of Common Ground Studio Ltd. Use or copying of the information on this plan without written permission of Common Ground Studio Ltd constitutes an infringment of copyright.
T (+64) 9 302 2200 www.cgstudio.co.nzAuckland Studio: L3 Queens Arcade, 17-21 Customs Street East, Auckland, NZ
Disclaimer: This plan has been prepared on behalf of and for the client. Common Ground Studio accepts no liability or responsibility in respect upon this plan by any third party.
Client
drawn
revproject
drawing
drawingpath
Project Name
Pedestrian Catchment TDS Combined PlansBy checked
Scale
project task
scale
date 1/1/11
Do not scale drawings. Verify all dimensions on site.
date bydetails
rev
name
size A#
By
P# T# DM-6 Afile.vwxPath
0 20 40 60 80 100 m
0 100 200 300 400 m
Halsw
ell R
oad
Hendersons Road
Augustine Drive
Aidenfield Road
Main
stree
t
Douglas CliffordStormwater Basin
KAC
400m
400m
No m
ore
than
300m
KAC boundary - Masterplan
KAC boundary - ODP
KAC CATCHMENT ANALYSISTDSL ALTERNATIVE MASTERPLAN / ODP
KAC - Masterplan/ODP 26.7 / 31.9 ha
Residential intensification 24.5 / 19.9 ha
Residential - existing 6.0 ha
1134 Danne MoraRebuttal: James Lunday with annexures
page 15 of 20
client:
© CopyrightThe concepts & information contained on this plan are copyright of Common Ground Studio Ltd. Use or copying of the information on this plan without written permission of Common Ground Studio Ltd constitutes an infringment of copyright.
T (+64) 9 302 2200 www.cgstudio.co.nzAuckland Studio: L3 Queens Arcade, 17-21 Customs Street East, Auckland, NZ
Disclaimer: This plan has been prepared on behalf of and for the client. Common Ground Studio accepts no liability or responsibility in respect upon this plan by any third party.
Client
drawn
revproject
drawing
drawingpath
Project Name
Pedestrian Catchment CCC ODPBy checked
Scale
project task
scale
date 1/1/11
Do not scale drawings. Verify all dimensions on site.
date bydetails
rev
name
size A#
By
P# T# DM-2 Afile.vwxPath
0 20 40 60 80 100 m
0 100 200 300 400 m
Halsw
ell R
oad
Hendersons Road
Augustine Drive
Aidenfield Road
Mai
nstre
et
Douglas CliffordStormwater Basin
KAC
400m
400m
No
mor
e th
an
300m
KAC CATCHMENT ANALYSISCCC ODP
KAC area 17.3 ha
Residential intensification 28.0 ha
Residential - existing 18.5 ha
1134 Danne MoraRebuttal: James Lunday with annexures
page 16 of 20
MENTZ Nolli
CCC KACIndicative Masterplan Nolli
RousehillTown Centre Nolli
1134 Danne MoraRebuttal: James Lunday with annexures
page 17 of 20
78,000M2 TOTAL FOOTPLATE
1134 Danne MoraRebuttal: James Lunday with annexures
page 18 of 20
Community
Housing
Parking
CarparkCarpark
Carpark
Carpark
Big Box Big Box
Big BoxBig Box
Sleeve Sleeve
SleeveSleeveSleeve
Entry to Carpark
Front
Back
Back
Front Back Front
Back
Front
1134 Danne MoraRebuttal: James Lunday with annexures
page 19 of 20
client:
© CopyrightThe concepts & information contained on this plan are copyright of Common Ground Studio Ltd. Use or copying of the information on this plan without written permission of Common Ground Studio Ltd constitutes an infringment of copyright.
T (+64) 9 302 2200 www.cgstudio.co.nzAuckland Studio: L3 Queens Arcade, 17-21 Customs Street East, Auckland, NZ
Disclaimer: This plan has been prepared on behalf of and for the client. Common Ground Studio accepts no liability or responsibility in respect upon this plan by any third party.
Danne Mora Holdings Ltd
drawn
revproject
drawing
drawingpath
Proposed North Halswell KAC Framework
KAC - Concept MasterplanSW checked
1:2000
project task
scale
date 28/4/15
Do not scale drawings. Verify all dimensions on site.
date bydetails
rev
name
size A3
BW
11020 - 11 11 KAC-E-12 AKAC Masterplan-Roads&Landscape.vwxPath
0 100 m
0 250 500 m
1134 Danne MoraRebuttal: James Lunday with annexures
page 20 of 20